Help Understanding EMR

[VK4WDM]

The ACMA are making the point that ALL stations that have ANY part of the antenna below 10m are by definition non-compliant. My guess is, that given the height restrictions in built up areas (only 8m where I live), 80% of all stations are non-compliant by that criteria (work out the mast height you need to have the ends of a 80m inverted V 10m above ground). Does the ACMA really want to be flooded by reports of all these non-compliant antennas?

And there is no point in collecting reports if they don't use them. So what are they going to do? Inspect them all? Unlikely with the number of field staff they have. Enforce a >10m height limit - I would lke to see them fight that through the various local councils! Enforce lower power limits? Stop these "non-compliant" stations operating at all?

I would like to see this news item backed up by an official statement from the ACMA before I get too worried about it.

73

Wayne VK4WDM

[VK4TI]

The ACMA are making the point that ALL stations that have ANY part of the antenna below 10m are by definition non-compliant. My guess is, that given the height restrictions in built up areas (only 8m where I live), 80% of all stations are non-compliant by that criteria (work out the mast height you need to have the ends of a 80m inverted V 10m above ground). Does the ACMA really want to be flooded by reports of all these non-compliant antennas?

And there is no point in collecting reports if they don't use them. So what are they going to do? Inspect them all? Unlikely with the number of field staff they have. Enforce a >10m height limit - I would lke to see them fight that through the various local councils! Enforce lower power limits? Stop these "non-compliant" stations operating at all?

I would like to see this news item backed up by an official statement from the ACMA before I get too worried about it.

73

Wayne VK4WDM

Where did you get this height thing , a url please as we both know just a few metres distance from an active antenna can be considered safe so how do the two relate I wonder , why do you even feel concern at home as certainly your station would be safe as is mine with verticals mounted less than 10 m high

[VK2OMD]

The ACMA are making the point that ALL stations that have ANY part of the antenna below 10m are by definition non-compliant. ...

Wayne, have you actually read and understood the relevant documents before launching this scare campaign?

The EMR (EME) assessment process required by the Apparatus Licence LCD has Level 1 criteria and Level 2 criteria (for the process).

If you meet Level 1 criteria no further assessment is required (as it is deemed low risk, you are regarded as compliant with the EMR (EME) requirements at that point - the converse is NOT stated or implied).

If you do not meet Level 1 criteria, you must follow the Level 2 assessment process, ie you must perform, or cause to be performed, an assessment according to the relevant documents.

The result of that assessment should be finding the safe distance from various RF carrying conductors under various power/modulation etc scenarios. You are determining the space from which people must be excluded for that scenario.

Obviously, among your immediate options are using lower power, or not transmitting at all. Longer term you can change things to become compliant at higher power level etc.

The buildup that if you have any part of your antenna below 10m you must inform the ACMA that you are non-compliant is confused and would give the ACMA further evidence that lots of hams have not got a clue about EMR (not that they need any more evidence).

If you write to the ACMA to advise them you are non-compliant with the EMR (EME) requirements because some part of your antenna is below 10m in height, you deserve to be served notice to not transmit until your station is assessed compliant by a competent person.

This is where the active dumbing down of ham radio has brought us!

Owen

[VK3ALB]

This morning's WIA broadcast further demonstrated the problems amateur operators (as a group) face regarding EMR compliance. The text of the broadcast is still available on the website as I write. In my opinion the most surprising statement of the article is "Under the LCD you have to notify ACMA in writing that the station is not compliant and you have 28 days to make the station compliant.". This statement was tempered by the final sentence, "However before contacting ACMA there are many changes that can be made to bring your station into compliance all of which are mostly common sense".

Sadly, the following sentence was probably missed by most as they were picking their jaws up from the floor or yelling at the radio.

I haven't found anything regarding self reporting anywhere in the LCD and it seems to be at odds with everything I have read about compliance. To me that statement is a akin to reporting yourself to the police because your Lamborghini can travel in excess of 200km/h.

[VK4WDM]

"Where did you get this height thing"

The short answer is: "nowhere official" - and that is a very important point.

The only place I have seen this statement about "all parts of the antenna must be above 10m to be compliant" is on the several threads on this logger that deal with EMF.

I would, like you, and many others, definitely like to see somebody post an official ACMA statement that verifies this as a requirement.

Obvious common sense requires an antenna to be high enough prevent somebody touching it whilst it is radiating and if you do a level 2 self assessment you will get a vertical and horizontal exclusion zone which only going to be a couple of metres.

We have to be careful not to jump at shadows, there is enough confusion as it is!

73

Wayne VK4WDM

[VK2OMD]

"Where did you get this height thing"

The short answer is: "nowhere official" - and that is a very important point.

The only place I have seen this statement about "all parts of the antenna must be above 10m to be compliant" is on the several threads on this logger that deal with EMF.

I would, like you, and many others, definitely like to see somebody post an official ACMA statement that verifies this as a requirement.

Wayne, you write this implying that there is such a requirement, and as there is not such a requirement you misrepresent the situation for whatever reason, your posting is fallacious.

The ACMA will not make such a verifying statment if there is no requirement.

I have asked you several times, and you have ignored the question; have you read the relevant documents, and do you comprehend them? Your postings are evidence you haven't... but it doesn't stop you commenting.

The inability on the part of many people to read and understand the legistlative instruments that apply to our operations confirms the ACMA's summary that there is a lack of awareness of the EME requirement.

VK1WX's expose on the WIA news is a further example, requirements snatched out of thin air it would seem.

And in that context, people want 1kW for Advanced, more power and other priveleges for Foundation. Collectively, we seriously lack credibility!

Owen

[VK2FXXX]

The ACMA are making the point that ALL stations that have ANY part of the antenna below 10m are by definition non-compliant.

Wayne that is just wrong.
You should read and understand this:
http://www.wia.org.au/members/technical/emr/
and further info:
http://www.wia.org.au/licenses/licensin ... _radio.pdf

Owen

This is where the active dumbing down of ham radio has brought us!

To discussing EMR ?
Are new amateurs dumb?
Can you expand on this statement?
Brendan

[VK4WDM]

Dear Owen and others who are jumping up and down on my head (don't worry it’s a hard head )

Please read ALL of my comments in ALL of the posts on this subject carefully and you will see quite plainly that most of the time I have been reflecting back comments that others have made so that they and others might have a re-think about where things might lead if that line of reasoning is continued. It is a very useful and common debating and discussion technique that I have used in my professional life for years, and applies to a lot of what I write in the forums. (I call it "stirring the pot to see what is soup, and what is bubble and froth").

For example. I just had a quick look at some of the treads and several people have mentioned the "height limit" - do I believe that to be correct? No, and VK2FXXX has pointed out an official statement to show that there is no such requirement, which I was hoping somebody would do.

Likewise, the news item on reporting of "non-compliant" antennas to the ACMA. If you read what I said, I am giving reason why this is unlikely, not supporting the idea. I was angling for the correct report of the news item and it was supplied.

So where do I really stand on EMF? (I have already said this in another thread but it has obviously been over looked).

1. I absolutely agree that hams need to be aware of, and comply with EMF regulations. We are a technically-based hobby. These sort of things should be our bread and butter.
2. Some of the statements by made on these threads are exaggerated or just plain wrong.
3. Personally, EMF compliance holds no terrors for me. I worked for many years in labs where radiation safety audits were a regular requirement.
4. Yes, Owen, I have read the documents. Do I understand them completely? Of course not, but I am not afraid to ask for help.
5. I have done EMR assessments on my station since they were first required. The last set was done a week ago when I changed an HF antenna. I have a new set of VHF and UHF antennas going up this week, and all of them will be assessed and changes made if they do not comply. I find these assessments interesting and fun.
6. Rather than a threat, I see the EMR regs as a wonderful opportunity for hams to do some really meaningful research on how to improve station efficiency whilst reducing the health risk.
5. The last blow of my own trumpet: I am a doctoral-level public health specialist that has worked on public health policy right up to United Nations level. No, this has not been in the field of radiation safety, but I do know a lot about legislation, and how to stir the pot to separate the soup from the froth and bubble!

Yep, I applied for the call sign VK4STIR but they would not give it to me!

73

Wayne VK4WDM

[VK2FXXX]

Yep, I applied for the call sign VK4STIR but they would not give it to me!

Try VK4 IBS instead!
Brendan.

[VK4WDM]

Brendan.

Now there is another thread on the same subject (EMR - again).

At least it's shaken the the AR community out of its usual apathy. And the F calls are having a chew on it too and providing some really good input which is good to see

73

Wayne VK4WDM

[VK2OMD]

Dear Owen and others who are jumping up and down on my head (don't worry it’s a hard head )
...

I think that in the first instance, there are conditions on our licence re EME, they have been there in similar form for a decade, and if we chose to operate within the law, then we must comply with them, preferably to understand and comply.

We have been found wanting where less than one third of the people who were granted a high power trial variation submitted an acceptable assessment in the required time dispite being warned by ACMA that they could expect to be asked to do that.

The way forward is to talk about real requirements, and real solutions (no, not Tony's Real Solutions (TM)). Real requirements are those laid down in the relevant documents, not BS like that in today's WIA broadcast (albeit not explicitly endorsed by the WIA) and some of the online discussions.

It is my view that assessments will be more complex than suggested by some people, and it is naive to think that a simple calculator tool is the universal answer to evaluation to RPS3. Indeed 'that' tool with its private methods figured in some of the assessment failures.

The BS factor is the reason why people must work from the source documents if they want to reliably understand their obligations, and especially if they want to perform their own assessments.

Owen

[VK2FXXX]

Brendan.

I was hoping you would take that in the manner intended.

Now there is another thread on the same subject (EMR - again).

Seems to be the hot topic at the moment.
I saw an interesting flyer posted on a community notice board today . It listed all the dangers of those "smart meters".
It started with something like : would you put a mobile phone mast in your house?
I thought to myself ,no I would put it ON my house.
Would they put a mobile phone to their ear? Wifi in their house? a cordless phone?
Apparently 5000+ scientific studies have confirmed the ill health effects of EMR!!!
Good night all.
Brendan

[VK4WDM]

t is my view that assessments will be more complex than suggested by some people, and it is naive to think that a simple calculator tool is the universal answer to evaluation to RPS3. Indeed 'that' tool with its private methods figured in some of the assessment failures.

OK, the VK3UM calculator is not perfect and my guess is that none of the other similar programs available from various AR groups are perfect either. But it is still a very useful tool and a good teaching aid in preparation for more detailed assessments that may be required using "source documents" as you say.

The WIA has already committed to an EMR education program, and those who are struggling are going to have lots of help available anyway. This is a technical hobby and in my 45 years in it I have seen plenty of situations where an extra effort was required to up-date knowledge - it took me a long time to get my head to move from valves to transistors, and a long time to move from CW/SSB to digital modes. Recently I have discovered antenna modelling software - currently a source of migraines - but this is what AR is all about. I will be struggling with something radio related until the men in the black ties and the station wagon pull up at the door. Even then I will be protesting "hang on - I need to check what happens in the VK3UM calculator if I delete that extra element and choose a less lossy feed line

73

Wayne VK4WDM

[VK3HJ]

Ok, how about the real EMR assessment of a Bobtail Curtain array?
The lower parts of the vertical elements are hot with high RF Voltage, and are close to the ground.
The top of the elements is where the current nodes are, and where maximum radiation occurs.
To address the voltage nodes, I have placed the lower parts of the radiators inside PVC tubing, to above where anything can reach from the ground. The feedpoint is insulated and contained by a barrier to keep the horses from walking through it. The current nodes are around 10 m above the ground.
A simplistic view would be to measure from the antenna at the ground - there obviously will be some radiation near the ends, but the maximum radiation is around 10 m above the ground.

This is the opposite situation of a quarter wave vertical, which is current-fed, therefore maximum radiation is near the bottom of the antenna.

The Bobtail Curtain is to be replaced by a yagi as soon as I can get the tower delivered and installed.

73,
Luke VK3HJ

[VK4WDM]

Sound's like it could double as a BBQ. Hang a couple of chooks in front of it (obviously dead ones!) and see how long they take to become nice and brown

[VK2AAH]

Luke is that why your horses start out grey & end up bays?

[VK2OMD]

Ok, how about the real EMR assessment of a Bobtail Curtain array?
The lower parts of the vertical elements are hot with high RF Voltage, and are close to the ground.
The top of the elements is where the current nodes are, and where maximum radiation occurs.
To address the voltage nodes, I have placed the lower parts of the radiators inside PVC tubing, to above where anything can reach from the ground. The feedpoint is insulated and contained by a barrier to keep the horses from walking through it. The current nodes are around 10 m above the ground.
A simplistic view would be to measure from the antenna at the ground - there obviously will be some radiation near the ends, but the maximum radiation is around 10 m above the ground.

This is the opposite situation of a quarter wave vertical, which is current-fed, therefore maximum radiation is near the bottom of the antenna.

The Bobtail Curtain is to be replaced by a yagi as soon as I can get the tower delivered and installed.

73,
Luke VK3HJ

Luke, some very traditional thinking there.

You did not mention the frequency, and it has a great bearing on the analysis that is acceptable.

Owen

[VK2AVR]

The ACMA are making the point that ALL stations that have ANY part of the antenna below 10m are by definition non-compliant.

Nope. I'll repost what I've just written in the other EMR thread as demonstrating compliance is actually very easy, you don't need to be anywhere near 10 metres height!

Direct quote from WIA's website, emphasis mine:

Compliance Level 1 applies if:

the transmitter is a mobile transmitter with an average total power output, fed to all antennas, of not more than 100 watts (W); or

the average total power supplied by the fixed station transmitter to all antennas fed by the transmitter is not more than 100 W, and each antenna fed by the transmitter is installed so that it is inaccessible to a member of the general public; or

the average total equivalent isotropically radiated power (EIRP) of all antennas fed by the fixed station transmitter does not exceed 3200 W in any direction and the minimum height of the lowest antenna fed by the transmitter is at least 10 metres above ground level.



So, an amateur home station operating a 400 W PEP SSB transmitter with low (or no) voice compression will have an average power of less than 100 W and therefore can be assumed to be Compliance Level 1, providing the antennae is inaccessible to the public.

If you want to get fancy then you can follow this PDF which is specifically tailored to amateur stations. Even so, the numbers in Table 2b are quite reasonable. If you run 100W SSB then your "effective average power" is 20 watts. Look down the 25 watt column and the highest number you can see is 2.8 metres for 28MHz, 9dBi antenna gain. Allow 2 metres for a tall human and you have 4.8 metres minimum separation. This is less than half of the council maximum of 10 metres.

Why are you all so upset?

[VK2CSW]

Why are you all so upset?

It is simple to answer this, it is a twofold answer:

1. Many of the posters are just trying to show their superiority - This is a common phenomenon throughout the interwebs, especially in hobby forums. I am not sure why but it feeds their ego I am told.

2. Many want to be bush lawyers. Knowledge and training doesn't matter here. Talking louder and repeating an opinion makes it true.

Now don't get me wrong, this is true in all types of forums on all types of subject not just here. Grumpy Old Man syndrome merely amplifies the effect.

[VK4WDM]

Grumpy Old Man syndrome

Can you be grumpy without being old, or old without being grumpy, or not a man and be grumpy, or old, or both old and grumpy? May be a better discussion point than the present one!

Geoff, I was only reflecting a statement that has been made by others on several different threads, so sensible people like you could knock it on the head by quoting the offical documentation. As have said else where, and as Luke points out here, ground-mounted antennas are going to need a level 2 assessment because they are "accessible to the public" (whatever that might mean).

73

Wayne VK4WDM